Jeremy T. Rosenblum

The Federal Deposit Insurance Corporation (FDIC) has issued a “Statement on Providing Banking Services” in which it “encourages institutions to take a risk-based approach in assessing individual customer relationships rather...more

The CFPB moved closer to likely rulemaking on overdraft programs with the release late last week of a new report entitled “Data Point: Checking account overdraft.”
The report is based on account-level and...more

In an unexpected move earlier this week, the FDIC issued a Financial Institution Letter (FIL) announcing that it was withdrawing the list of “risky” merchant categories that was included in prior guidance on account...more

In an unexpected move earlier this week, the FDIC issued a Financial Institution Letter announcing that it was withdrawing the list of “risky” merchant categories that was included in prior guidance on account relationships...more

"Operation Choke Point," the coordinated multiagency federal effort to choke off banking services to alleged fraudsters (according to its defenders) or politically unpopular industries (according to its detractors), has come...more

The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have carried out their threats in their proposed guidance to kill deposit advance loans. On November 21, 2013, the two...more

Last week, the FDIC issued the latest in a series of Financial Institutions Letters dating back to 2008 on the subject of banks managing third-party risk. This most recent FIL deals with payment processing for third-party...more

A friend brought to my attention a two-page comment letter from Senators Elizabeth Warren and Bill Nelson, commenting on the OCC’s proposed deposit advance guidance, the subject of a prior blog....more

The Federal Trade Commission recently brought an enforcement action against a company that processed credit card payments for the operator of an alleged debt relief telemarketing scam. This action serves as a reminder to...more

Last Thursday, the Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation proposed guidance on deposit advance loans. The Federal Reserve Board declined to join the OCC and FDIC and instead...more

Earlier today, the CFPB released a white paper reporting on its study of 15,000,000 storefront payday loans and 100,000 accounts eligible for deposit advances (of which approximately 15% involved a deposit advance during the...more